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ACR Electronics, Inc. v. Switlik Parachute Co.

Citations: 624 So. 2d 1144; 1993 Fla. App. LEXIS 7883; 1993 WL 280452Docket: No. 92-1902

Court: District Court of Appeal of Florida; July 28, 1993; Florida; State Appellate Court

Narrative Opinion Summary

This case centers on a contractual dispute between a buyer and a seller regarding the supply of parts essential for the buyer's manufacturing operations. The seller breached the contract by refusing to sell the parts at the previously agreed price, prompting the buyer to secure the necessary parts from another source at a higher cost. The trial court ruled in favor of the buyer, awarding damages for the breach. Upon appeal, the appellate court affirmed the trial court's judgment but modified the damages award. The appellate court determined that the seller was justified in implementing a 3% price increase effective February 1991, the date of the seller's initial price adjustment attempt. Furthermore, the appellate court found that the trial court erred in awarding prejudgment interest from February 1, 1991, as the buyer did not sustain damages until it procured the parts at a higher price. Consequently, prejudgment interest should be calculated from the date when the buyer incurred actual damages. The appellate court's decision was unanimously affirmed in part and reversed in part.

Legal Issues Addressed

Breach of Contract for Sale of Goods

Application: The seller's refusal to sell the parts at the agreed price constituted a breach of contract.

Reasoning: The trial court found that the seller breached the contract and awarded damages to the buyer.

Modification of Contract Terms

Application: The court recognized the seller's right to impose a price increase starting from February 1991.

Reasoning: The court ruled that the seller was entitled to a 3% price increase starting from February 1991, when the seller first attempted to impose this increase.

Prejudgment Interest Application

Application: Prejudgment interest should only apply from the date the buyer incurred actual damages, not from the date the contract was breached.

Reasoning: The court held that the trial court incorrectly awarded prejudgment interest from February 1, 1991, since the buyer did not incur damages until later, when it had to purchase the parts at a higher price.